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Frequently Asked Questions (FAQ) on the Globally Harmonised System of Classification and Labelling of Chemicals (GHS) - 2014

No. CATEGORY QUESTION ANSWER

The main objective of The Globally Harmonized System of Classification and Labelling of Chemicals or GHS is an
GHS is to have a single internationally agreed-upon system created by the United Nations. It is designed to replace
harmonised system the various classification and labelling standards used in different countries by using
worldwide. However the consistent criteria for classification and labelling on a global level.
1* Compliance
implementation time-
frame and standards The adoption of the GHS is expected to facilitate international trade by increasing consistency
differs for some between the laws in different countries that currently have different hazard communication
countries. requirements. There is no set international implementation schedule for the GHS. Different
countries will require different time frames to update current regulations or implement new
ones.

GHS hazard communication is developed by the United Nations which encourages member
Is GHS classification & states to adopt for safeguarding persons against hazardous chemicals. Singapore has
labelling of chemicals adopted the GHS and under the WSH (General Provisions) Regulations which are
2 Compliance mandatory in administered by MOM, chemical suppliers must provide SDS for their hazardous chemical
Singapore? products, and any occupier of a workplace must label the containers of hazardous
substances. The law has recently been amended by making reference to SS 586 on GHS. SS
586 has also been gazetted as an Approved Code of Practice under the WSH Act.

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The GHS implementation timeline in Singapore is as follows:

3 Compliance What is the GHS Timeline


Manufacturers/Suppliers
implementation timeline
in Singapore? Single Substances

All hazardous substances except ozone depleting Feb 2012


substances, chemically unstable gases, aerosols,
sensitisers
(based on GHS purple book Rev 2)

Ozone depleting substances, chemically unstable 1 Jul 2015


gases, aerosols, sensitisers (based on GHS purple
book Rev 4)
Mixtures 1 Jul 2015

Users Timeline

Single Substances

All hazardous substances except ozone depleting End 2012


substances, chemically unstable gases, aerosols, sensitisers
(based on GHS purple book Rev 2)

Ozone depleting substances, chemically unstable gases, 1 Jul 2015


aerosols, sensitisers (based on GHS purple book Rev 4)

Mixtures 1 Jul 2016

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Why is the GHS
Single substances are easier to classify compared to mixtures. Furthermore, data and
transition period for
information on hazard classification, labelling and SDS for most single substances are readily
single substances
4 Compliance available in the public domain. Therefore, a shorter timeline is given for GHS implementation.
different from that for
mixtures? Mixtures are composed of different substances. They are often complex and therefore a
longer time timeline is needed for hazard classification and SDS preparation.

Anyone (including importer, exporter, trader or company) responsible for or involved in the
importation, trading or marketing of chemicals in Singapore is expected to comply with the
Who is responsible for
complying with GHS local requirements of GHS.
when a chemical is
5 Compliance imported into, exported The same applies when exporting chemicals to a country which has implemented the GHS.
out or traded in
Further to the above, Users of chemicals must also comply with the relevant requirements of
Singapore ?
the GHS under their respective countrys local regulations.

GHS has been


implemented in many
countries but at different
timelines. If I import
chemicals from countries Importers of hazardous chemicals must ascertain that the chemicals imported are provided
which have yet to with GHS labels and SDS. Any local importer importing hazardous chemicals without GHS
implement GHS, I will labels and SDS has to re-label the product package and prepare the SDS in accordance with
6 Compliance
not be able to comply the GHS format if the chemicals are to be sold or marketed in Singapore. It would therefore
with the GHS be more cost-effective and less troublesome for local importers to import chemicals from
requirements in respect overseas suppliers who are able to provide GHS labels and SDS for their products.
of labelling and SDS for
the chemicals imported.
What should I do in
order to meet the local
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GHS implementation
timeline?

Generally Singapore has adopted the higher (i.e. less stringent) generic concentration limit,
Does Singapore adopt
consistent with key trading partner countries adoptions. However, there is this Hazard Class
High or Low thresholds
7 Compliance whereby if a STOT Category 1, is present at 1-10%, the mixture will be classified as Category
for GHS classification
2. The UN allows countries to decide if it will be a CAT 2, or NOT. Singapore has decided on
purpose?
CAT 2 (i.e. more stringent in this case).

We had delivered some


chemicals to our
customers a few years
ago and some of these
chemicals (single
substances) did not have
a GHS label at that time.
Will it be the companys
responsibility when our The labels provided to the customers should be the correct labels for the chemicals which
customers who they have requested. The customers who are the users of the chemicals will have to check
8 Compliance
requested GHS labels that the labels which they are replacing should tally with the labels affixed to the original
from us for those bottles, containers.
pasted them onto the
wrong chemical bottles?
Is there anything we
need to ask our
customer to take care of
when using these GHS
labels?

9 Compliance My company imports In this scenario, there is no requirement to affix Singapore GHS-compliant label to each
products from other container given that the companies have to ensure that the DG (Dangerous Goods) labels
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countries to Singapore and/or origin countries GHS compliant label is affixed to the drum and consignments.
for re-export purpose. Companies, whether subscribing to third party warehouses and/or using own warehouses,
They will be stored in the must ensure they have the necessary licences from relevant government agencies (i.e.
warehouse until the time Hazardous Substances under NEA; Petroleum & Flammable Materials under SCDF and
for re-export to a explosives & explosive precursors under SPF) before storing the chemicals in the warehouse.
destination country.
There are DG labels (Please also refer to Q10.)
and/or GHS labels of the
origin countries on the
products. Does my
company need to apply
Singapore GHS-
compliant label on the
products when stored in
the Singapore
warehouse?

My company
manufactures chemical
products in our own
plant, which are stored in Yes, for chemicals manufactured in Singapore for export purpose, company may use reduced
the warehouse until the workplace GHS label (which indicates chemical name and GHS pictograms) at the storage
time for export to a area or on the pallet. The reduced workplace label should be visible to the workers at storage
10 Compliance warehouses. All export and re-export chemical packages should be labelled in accordance
destination country.
Does my company need with export countrys regulatory requirement.
to apply Singapore GHS-
compliant label on the
products when stored in
the warehouse?

How do we comply with It is a usual practice for the UN documentation (standards or codes) to be revised from time to
11 Compliance GHS requirements if time so as to remain relevant. However, the amendments are usually refinements or additions
SS586 is going to be in nature rather than making fundamental changes to the original GHS document (Purple
revised once every 2 Book). Therefore, the amendments or changes will not be expected to affect most of the
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years or at the same existing chemicals that have already been classified. The national GHS Task Force (which
frequency as the UN coordinates the implementation of GHS in Singapore) takes into consideration the local
GHS revision? context and consults relevant stakeholders when reviewing or updating the SS 586 to align
with the UN GHS Purple Book.

Different countries will


have their own The GHS document provides countries with the flexibility to adopt building blocks which meet
requirements on the their respective domestic requirements. Although there may be differences in categories
12 Compliance
building blocks adopted, adopted by different countries, the overall key information such as labelling elements;
how then is GHS pictograms, signal words, hazard and precautionary statements are harmonized.
harmonised?

GHS does not exempt any chemical substances/mixtures, except for the following:-

those classified as non-hazardous by GHS hazard classification


those which do not contain any hazardous ingredients above the SDS cut-off limits as
Is any chemical guided by SS586 Part 3 Table 1
13 Compliance exempted from GHS traces of food additives or pesticides in food *
labelling and SDS?
pharmaceutical products (at the point of human intake or ingestion) *
cosmetics (at the point of intentional application) *
veterinary products intended for application to animals *

Note:- (*) These products will not be covered in terms of labelling at the point of intentional
intake but will be covered where workers are exposed in the workplace and in transport.

Is there any official There is no official language stipulated in the GHS requirements for labelling. When exporting
language specified for to any country, you would have to comply with the local requirements (which may cover
14 Compliance GHS label? Are multi- language) as set by that particular country.
languages labels
permissible? In Singapore, English is a business language used for SDS and labels. Under the WSH
(General Provisions) Regulations, it is mandatory to have warning labels in languages
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understood by all persons at work, depending on the demographic of the workforce.
Pictograms serve as a tool to guide and train workers. Translation of GHS pictograms in
several languages can be obtained from the following website:
http://great.cla.gov.tw/ENG/download.aspx?classifyId=3

There is generally no difference as part of harmonisation, the GHS and UNTDG testing
Is there any difference
requirements / rules on physical hazards and the end points have been aligned. In the 14th
between the physical
15 Definition edition of the UN Recommendation on the Transport of Dangerous Goods (UNTDG, the
hazards as determined
Orange Book), the classification and labelling of DG have been harmonized with GHS to a
by GHS and UNTDG?
large extent.

Different regulators have different definitions. See summary table below.

Competent
tank DG GHS SEIP TEIP
Authority
What is Singapores
SCDF Bulk >250 L
16 Definition definition of bulk versus
packaged tanks? NEA Bulk >450 L

SCDF Package <250 L

NEA Package <450 L

A single substance is a chemical element or its compound in the natural state or obtained by
What is the difference any production process, including any additive necessary to preserve the stability of the
between a single product and any impurities deriving from the process used, but excluding any solvent which
17 Definition may be separated without affecting the stability of the substance or changing its composition.
substance and a
mixture? A mixture means a mixture or a solution composed of two or more substances in which they
do not react.

18 SS586 When will the SS 586 be SS 586 has already been gazetted as an Approved Code of Practice (ACOP) under the
an Approved Code of Workplace Safety and Health (Approved Codes of Practice) Notification 2011, effective on 15
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Practices (ACOP)? Feb 2011.

SS 532 for the storage of flammable liquids provides technical requirements for safe storage
There are some
of flammable liquids in fixed bulk installations and in packages. The definition of flammable
similarities in the
liquids is according to the GHS flammable liquids; and in additional liquids with flash point
requirements for
more than 93 degree C and up to including 150 degree C are to comply with the requirements
labelling in SS 532 on
of category 4. It recommends the use of hazard labelling such as symbol, pictogram, signal
storage of flammable
19 SS 586 word, hazard and precautionary statements of GHS flammable liquids.
liquids and SS 586 Part
1. What should be the SS 586 Part 1 for hazard communication for hazardous chemicals and dangerous goods
requirements for storage provides guidelines on labelling requirements for transport and storage of dangerous goods. It
of chemicals? is based on the UN Recommendations for transportation of dangerous goods, and it provides
comprehensive information for the emergency responders, workers and public on the
associated physical risks of the chemicals being transported or stored.

I have a warehouse of
chemicals and at the
entrance I have SS 508 is the requirement for factories on warning notices to warn or remind the target
displayed all the warning audience (workers at work) of possible dangers such as high voltage, wear protective
notices complying to SS clothing, certain nature of hazard etc.
508 and with this new
SS 586 part 1 on SEIP SS 586 Part 1 targets emergency responders and people who may not aware of the presence
20 SS 586 my entrance will be of physical hazards arising from the hazardous chemicals stored inside the premises.
flooded with warning
signs. Thus, there is minimum repetition between SS 508 and SS 586.

How I can manage the For chemical warehouse where diverse range of hazardous chemicals are kept, only UNTDG
signs to comply with label is required at the entrance, not SEIP. SEIP is more for out-door storage such as bulk
both SS such that tank farm or drums store, where single hazardous chemicals are kept at one place.
people are not
confused?

Safety Data What is the difference There is no difference. The use of this title varies from country to country. For the purpose of
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Sheet between SDS (Safety harmonisation internationally, the UN Sub-Committee of Expert on the GHS Classification and
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Data Sheet) and MSDS Labelling has standardised it to Safety Data Sheet (SDS). Singapore has adopted this.
(Material Safety Data
Sheet)?

Do traders need to This would depend on whether the trader is selling on behalf of the company which could use
prepare and create their the trademark / logo, etc. In this case, they could use the supplier SDS. If the trader is to sell
Safety Data own SDS or can they and market the product under its own brand name and company, the trader would need to
22 use the copy from the create its own version of the SDS including contact details and emergency response contact
Sheet
company? number.

Whenever there are


changes in the contents No, there is no legal requirement for the changes to be highlighted. It should be the
Safety Data of the SDS, is it responsibility of the manufacturer to issue a new or revised SDS whenever there are changes
23 in properties or contents of the chemical.
Sheet necessary to highlight
these changes in the
new / revised SDS?

Must a new SDS be


issued when a chemical
No. The SDS of the original/pure chemical can be used if there are no other chemicals
Safety Data is diluted (e.g. a 99%
24 present. In addition to the SDS, additional information related to the revised diluted
Sheet concentrated alcohol is
concentration should also be provided.
diluted to 70%
concentration) ?

In general, all hazardous chemical storage drums need to be labelled in accordance with SS
Storage of chemicals in 586 i.e. the drums must be affixed with a GHS label. If the drums are to be transported by an
drums, do we need a open vehicle to another location, additional UNTDG label is required on the drums.
25 Labelling
GHS label for each
drum? Please refer to SS 586: Part 1 and SS 586:Part 2 - Section 6.3 (Reduced Workplace
labelling) for details.

26 Labelling Is there a size


Currently there is no size requirement for the pictogram but there is a minimum size
requirement for the
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pictogram to be used on dimension for GHS labels which can be found in the Singapore Standard SS 586 Part 2.
the label under GHS
standards?

Can we combine the Yes, they can be combined under GHS labelling. Please refer to SS 586 Part 1 for the size
transport and workplace requirement on transport label and Part 2 for the label elements to be stated.
27 Labelling
product label to just one
label?

Under GHS, pictograms prescribed should have a black symbol on a white background with a
Can a GHS label be red frame sufficiently wide to be clearly visible (black border is acceptable if the product is not
28 Labelling printed on a coloured for export) regardless of the colour or background of the paper used.
paper/background?
Please refer to SS 586 Part 2 for details.

If the label could not fit


all hazards/pictograms, There can be a maximum of four pictograms on the label and all hazard statements are to
29 Labelling
is it possible to leave out be included.
some?

The use of a blank diamond space pictogram with a red (or black border) or any other related
Can a blank diamond combinations on a printed label is currently being reviewed by the United Nations GHS Sub-
space pictogram with red committee. In view of this pending decision on the issue by the UN Sub-committee, for the
30 Labelling
(or black) border be interim, the use of existing pictograms as currently practised by the industries is acceptable in
printed on the label? Singapore. However, exporters must check on the local requirements of the other countries if
the product is to be exported or for use in that respective country.

Is there a requirement GHS label is only required for a chemical that is classified as hazardous under the GHS
for vacuum pumps or classification criteria. It also applies to packed-in containers (e.g. drums, pals and bottles or
POU abatement that small containers).
31 Labelling may deliver or contain
hazardous chemicals be This is not for equipment or tanks. Refer to the GHS guideline (SS 586) for more details.
labelled with GHS
chemical labels?

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There are numerous databases listing substances and their classifications and resulting label
elements in the internet. Some of these are country specific and offered by the competent
authority e.g. Korea and Japan.
Are there available
databases to assist in Notwithstanding the availability of these databases, a company will need to review and carry
32 ** Miscellaneous out its own assessment based on the chemical and component details to determine the
classification and
labelling? hazard classification of the chemical substance. It is also recommended that the company
maintains proper house-keeping records of the classification process for future references,
particularly so when the classification process has to be reviewed due to changes in the GHS
criteria.

Generally in most countries, consumer packages (purchased off the retail shelf in
Is GHS labeling required supermarkets and stores) which contain hazardous substances do not have to be GHS
for consumer products labelled.
33 *** Miscellaneous
which contain hazardous
substances? However, in some countries e.g. Japan, they do provide GHS labels on consumer
packages/products such as soap and detergent. This practice is however voluntary.

What is the relation HS Code is used for the identification of products (including chemicals) in Singapores Trade
34 Miscellaneous between HS Code in Net for custom clearance. It is for Import/Tariff Tax which in principle has no relation to GHS.
Trade Net and GHS?

If I do the classification
Regulatory authorities or agencies have the right to know or challenge the classification
for the chemicals, would
35 Miscellaneous especially if there is any query or complaint from an end-user. Hence, it is advisable to keep
my classification be
and make available all the records and data on how the hazardous chemicals are classified.
challenged?

Please contact the Singapore Chemical Industry Council (SCIC) by Tel. 6267 8891, email
Is there a course for secretariat@scic.sg or visit SCIC website at www.scic.sg for more information.
36 Miscellaneous
mixtures classification?

To purchase Singapore Standards, please go to www.singaporestandardseshop.sg. The full


37 Miscellaneous Where can a copy of the
collection of Singapore Standards may be viewed at SPRINGs reception area (1
Singapore Standard SS
Fusionopolis Walk, #01-02 South Tower, Solaris, Singapore 138628), as well as the Lee
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586 be obtained? Kong Chian Reference Library (National Library Building, 100 Victoria Street, #07-01,
Singapore 188064).

Notes

SS 508: 2004 Part 3 Graphical symbols Safety colours and safety signs use at workplace and public areas
SS 532: 2007 Code of practice for the storage of flammable liquids (formerly CP 40: 1987)
SS 586: 2014 Specification for hazard communication for hazardous chemicals and dangerous goods
Part 1: Transport and storage of dangerous goods
Part 2: Globally harmonised system of classification and labelling of chemicals - Singapore's adaptations
SS 586: 2008 Specification for hazard communication for hazardous chemicals and dangerous goods
Part 3: Preparation of safety data sheets (SDS)

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